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Letter-Attachment To-Sarah-Pearse-GCC-Planning

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Leckhampton with Warden Hill Parish Council For the attention of Sarah Pearse MA BSc MRTPI Principal Planning Officer Strategic Infrastructure Planning - Development Management Gloucestershire County Council Shire Hall, Westgate Street, Gloucester. GL1 2TH 29th June 2020 Application by Head of Property Services, Gloucestershire County Council for Construction of a new 6 forms of entry secondary school building, with a new all-weather pitch, sports playing fields, a multi-use games area, onsite parking and other associated works at Land Between Farm Lane/Kidnappers Lane Cheltenham Gloucestershire (application no: 19/0058/CHR3MJ) Dear Sarah The High School Leckhampton Application: concerns and risks We understand that GCC plans shortly to approve the application. As you are aware the Parish Council is concerned about several issues in the application and we believe that GCC has not properly addressed the requirements of the NPPF in respect to valued landscape and may be at risk of legal action by local residents over this. In addition the recent announcement about changes to the catchment area undermines the basis for the previous traffic modelling and suggests that this should be recalculated as it significantly increases the risk of even worse traffic congestion than before. The Leckhampton Fields are designated as valued landscape by the Secretary of State and fall under NPPF paragraph 170 which states that: ‘Planning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan).’ In the case of the Leckhampton Fields, the development plan is the Gloucester-Cheltenham- Tewkesbury Joint Core Strategy and the Cheltenham Local Plan which is awaiting adoption delayed by the Covid-19 lockdown. At the 14 May meeting, in answer to a question from Councillor Will Windsor-Clive, you confirmed that you were unaware of the significance of the valued landscape and that there was no mention of the valued landscape in the report by GCC’s landscape consultant or any consideration of the valued landscape in the application documents. Ms Arlene Deane - Clerk Leckhampton with Warden Hill Parish Council The Gate House,Cedar Court, Humphris Place. Cheltenham GL53 7FB T: 01242 465762 M: 07739719079 E: [email protected] Leckhampton with Warden Hill Parish Council The attached paper elaborates on what Cllr. Dr Adrian Mears and Cllr. Martin Horwood said to the GCC Planning Committee at the 14 May meeting and has recommendations on how we think the issues might be addressed. In particular we believe that GCC urgently needs to examine the issue of the valued landscape and produce a clear and deliverable plan to meet the NPPF requirement that it has so far ignored. We are copying this letter to all the members of the GCC Planning Committee, Simon Harper, Alex Chalk MP, Tracey Crews and John Rowley at CBC, Shurdington Parish Council and the four other Cheltenham Parish Councils. Yours sincerely Mrs Penny Henty Chairman Ms Arlene Deane - Clerk Leckhampton with Warden Hill Parish Council The Gate House,Cedar Court, Humphris Place. Cheltenham GL53 7FB T: 01242 465762 M: 07739719079 E: [email protected] Submission by Leckhampton with Warden Hill Parish Council June 2020 concerning Gloucester County Council application number 19-0058-CHR3MJ Introduction The site for this new school, which is named ‘The High School Leckhampton’, is located in Leckhampton with Warden Hill Parish and the Parish Council has made several submissions to consultations on the school proposals. The Parish Council has supported the school in principle but has serious concerns about what is actually being proposed, primarily over failure to protect the valued landscape of the Leckhampton Fields in accordance with NPPF para 170, the impact on the ecology and protected species, and the increase in the traffic congestion in the peak morning period. These issues were covered briefly in the speech to the GCC Planning Meeting by Cllr. Dr Adrian Mears on behalf of the Parish Council and on the ecology issues in the speech by Cllr. Martin Horwood, who is a member of Cheltenham Borough Council and also of the Parish Council. The purpose of this document is to elaborate on these points and jointly find solutions. Historical background The site of the school was previously identified as land for housing as part of the Leckhampton Strategic Allocation in the draft Gloucester-Cheltenham-Tewkesbury Joint Core Strategy (JCS). This proposed strategic allocation, which derived from the revoked 2006 South West Regional Spatial Strategy, was for around 1200 homes of which around 180 were on the GCC land that is the site for the school. Another 650 were on land east of Kidnappers Lane and a further 377 were on land west of Farm Lane that is in Tewkesbury Borough. The application for the 650 homes east of Kidnappers Lane was made by Bovis Homes and Miller Homes in 2013 and was refused by Cheltenham Borough Council in 2014 and subsequently refused on appeal by the Secretary of State in 2016. Importantly, this refusal was made on grounds of valued landscape and severe cumulative traffic congestion both of which are highly relevant to the application for the school. The application for the 377 homes west of Farm Lane was approved by Tewkesbury Borough Council in 2016 and was permitted by the High Court following a judicial review. That development is currently under construction. In 2015 the Parish Council and Councillor Iain Dobie as the county councillor for Leckhampton and Warden Hill wrote to GCC seeking more secondary school places in the area and recommending that GCC should reserve its land for a playing field for a future secondary school rather than using it for housing. In response GCC repeatedly insisted that there was absolutely no need for a new secondary school in south Cheltenham and gave an option for housing on its land to a developer. In 2016, the JCS Examiner, Inspector Elizabeth Ord, concluded that the Leckhampton Strategic Allocation was unsound on landscape grounds and recommended that development should be limited to the so-called Northern Fields, which are the part of the Leckhampton Fields bordering the A46 on its south-east side. During the JCS Examination Inspector Ord also at the request of all parties examined a proposal for a Local Green Space (LGS) that was put forward in 2013 by the Parish Council as part of its neighbourhood planning. In her findings she concluded that the proposed LGS was sound. The LGS included the GCC land that is now the site for the new school. Page 1 GCC had not raised any potential need for a new secondary school in South Cheltenham in its submissions to the Joint Core Strategy or to the draft Cheltenham Plan. But in 2017, following the rejection by Inspector Ord of any housing on its land, GCC proposed instead to use the site for playing fields for a secondary school for 900 pupil places with the school buildings themselves located in the housing allocation on the Northern Fields north of the GCC land. This proposal was inserted into the draft Cheltenham Plan in December 2017 just before its submission, with a proviso that the extra traffic caused by the school together with the traffic from the new homes proposed on the Northern Fields must not cause severe traffic congestion. The Parish Council agreed to this proposal provided that the playing fields were grass with no floodlighting and that any tennis courts were located on the north of the two GCC fields and concealed from view behind the existing boundary hedgerow between the two fields. In 2018, GCC changed its mind and decided it wanted to put the whole of the school including the school buildings on its own land. GCC stated that the reason for the change was that it did not have a strong enough case for compulsory purchase of the required land on the Northern Fields and it might also have to pay high compensation given the land was allocated for housing in the draft Cheltenham Plan. CBC and the Parish Council both opposed this change and in its evidence to the examination of the Cheltenham Plan in February 2019 by Inspector Wendy Burden CBC’s counsel said that CBC expected that Miller Homes, the developer, would make the necessary land for the school buildings available. At that time GCC and Miller Homes were collaborating and they put a joint proposal to Inspector Burden on the traffic mitigation. Despite CBC's recommendation, Inspector Burden found in favour of allowing the school buildings to go on the GCC land, although she retained the caveat over the impact on the traffic being acceptable. A factor in her decision was the shortfall in housing supply due to uncertainty over other planned developments in Cheltenham. This caused her to ask for the allocation on the Northern Fields to be increased. Removing the school buildings from the Northern Fields provided space for more homes. The collaboration between GCC and Miller Homes subsequently broke down and GCC has developed a standalone application for the school that is independent of what is being proposed by Miller Homes. This is suboptimal because it does not make use of the foot and cycle routes to the school proposed by Miller Homes through the Northern Fields. As a result GCC has been forced to promote an alternative footpath and cycle track via the public footpath across Lotts Meadow (subject to agreement by the landowner) and by building a cycle track and footpath along Kidnappers Lane. Currently Kidnappers Lane is a narrow rural lane with protected trees and old hedgerows and is an important component of the valued landscape.
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